CMS Solicits Comments on Addressing Health Inequities in IRFs and Proposes Updates to the IRF Quality Reporting Program

On April 7, 2021, the Centers for Medicare & Medicaid Services (CMS) released the Inpatient Rehabilitation Facility (IRF) Prospective Payment System (PPS) Proposed Rule for FY 2022.

Health Equity RFI

As part of this rule, CMS also released a request for information (RFI) seeking comments on revising measure development and the collection of Standardized Patient Assessment Data Elements (SPADEs) to address health equity in inpatient rehabilitation facilities.

This RFI is being released as part of the Biden Administration’s commitment to advance health equity and the Executive Order (EO) on Advancing Racial Equity and Support for Underserved Communities Through the Federal Government. In response to evidence of persistent inequities in health outcomes in the United States, CMS is seeking guidance on improving quality in the post-acute care environment. The RFI indicates that one strategy for addressing inequities is by improving data collection to allow for better measurement and reporting on equity across post-acute care programs and policies.

CMS indicated that they do not intend to respond to comments in the final rule but feedback will be used to inform future policy making.

IRF Quality Reporting Program

The IRF QRP is a pay-for-reporting program and facilities that do not meet reporting requirements are subject to a two percentage point reduction in their Annual Increase Factor. There are several proposals related to the IRF QRP in the proposed rule

  • Measure Addition: CMS is proposing to require IRFS to report the COVID-19 Vaccination Coverage Among Healthcare Personnel Measure. This measure would help assess if IRFs are taking appropriate steps to limit the spread and reduce the risk of transmission of COVID-19 in their facilities.
  • Measure Modification: CMS is proposing to modify the Transfer of Health (TOH) Information to the Patient-Post Acute Care (PAC) Measure, to better tailor this measure for the IRF environment by removing from the measure denominator patients discharged home under the care of an organized home health service organization or hospice.
  • Public Reporting: In light of COVID-19 and the flexibilities that were previously provided around quality data submission requirements, CMS is now proposing to revise policies around the public reporting of quality measures that may have limited data reported.
  • Digital Quality Measures: CMS is also seeking feedback on future plans for digital quality measures.

The proposed rule is scheduled to be published in the Federal Register on April 12 and comments are due on June 7.


For more information visit the McDermottPlus Payment Innovation Resource Center or contact Sheila Madhani or Kristen O’Brien.